The non-profit organization's comments argue that the E-rate program has been "extremely successful" and offers four recommendations for reform, including a boost in available funds, establishment of national bandwidth goals, a focus on broadband connectivity and an increase of discounts for rural schools and libraries.

ISTE's first recommendation is that the FCC should more than double the available funds from $2.25 billion each year to at least $5 billion. The organization argued that without such a permanent increase, the gap between what schools and libraries need and what they can provide will widen, rural and remote schools and libraries will only receive funding for priority I funds and will fall behind their "better heeled counterparts" and that digital learning advancements will be undermined or "torpedoed" altogether.

"Most of my students do not have a computer much less the Internet at home. Most only have access at school," Nancy Tom, a teacher from Harlandale Independent School District said, in a prepared statement. "I use digital learning to meet Common Core State Standards, administer online assessments and make data-driven decisions… After school, I take the time to assist students with career opportunities and online applications. However, Harlandale does not have the funds to keep up with demand, and the need for a reliable high-speed network is only going to increase in the near future. We do the best that we can, but we are always at least 3 years behind technology. I urge you to raise the E-rate funding level to at least $5 billion per year, which is close to the average demand level for each of the past two years. Harlandale depends on E-rate and could not function without (it)."

The organization also argued "that the FCC must move from measuring the existence of an Internet connection to measuring the strength of that connection" and should establish bandwidth goals informed by data collected from E-rate applicants.

Citing a lack of funding for internal connections over "many years," ISTE recommended that wireless LAN controllers and access points be moved to Priority I to improve broadband connectivity within schools and libraries.

The organization pointed to bring-your-own-device programs, 1:1 computing initiatives, online textbooks, Internet research and surveys suggesting teachers want to be able to use more technology in the classroom as reasons to beef up those internal connections.

"While ISTE agrees that all aspects of a network — both the internet connection to the building and the internal network within a building — are important, wireless LAN controllers and wireless access points are becoming increasingly critical to ensuring that the increasing number of devices in schools can connect to high-speed internet access," wrote ISTE CEO Brian Lewis.

The organization's final recommendation is that the 10 percent additional discount available to rural and remote schools and libraries in some situations be increased to 15 percent.

"Education funding in Missouri has been eight to 10 percent below full funding for five years, and we are struggling financially to provide a quality education for our students," wrote Heath Halley, superintendent of Putnam County Schools, in a statement submitted to the FCC. "E-rate assistance is essential to our budget. We are also part of a four-school consortium that uses a distance learning network to provide educational services to the four schools. All four schools are small and rural and are not able to provide all curriculum requirements. For example, Green City Schools has a certified physics teacher; she provides physics to all four schools. Putnam County has a Spanish teacher and she provides Spanish to all the schools as well. The interactive system is built on a fiber optic network and the large fees are paid in part with E-rate funding each year. For our school, E-rate is a successful program that we continue to rely on and a program that must continue to provide funding critical for telecommunications and connectivity. Changes in the E-rate program could easily cause the distance-learning network to disband, as each school in the consortium is facing continued cuts of state funding. Each school's students would then lose educational opportunities which are important to their future success."

"ISTE commends the Commission for launching this timely rulemaking on this most essential program," wrote Lewis. "The E-rate has enjoyed 15 years of sterling success and we believe, with some appropriate refocusing and increased funding, the program can continue to ensure that all of our nation's K-12 schools and libraries will gain access to the bandwidth they need for digital learning in the coming decades. ISTE's members look forward to working with the Commission to ensure that E-rate becomes stronger and that all students, educators and library patrons can truly be connected learners."

About the Author

Joshua Bolkan is contributing editor for Campus Technology, THE Journal and STEAM Universe. He can be reached at jbolkan@gmail.com.

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